National Science Foundation (NSF) Conflict of Interest

The National Science Foundation (NSF)
issued final policies in the July 11, 1995 Federal Register
that relate to award conditions and revised requirements
for proposal submission in order to insure that institutions
maintain written and enforced policies on investigator
conflicts of interest. This policy change was effective
October 1, 1995.

The policies outline the following
institutional responsibilities:

Have a written policy regarding
conflicts of interest.

Designate one or more persons
to review financial disclosures and conflict of interest
issues.

Effect adequate enforcement
mechanisms and responses.

Maintain records of disclosures
and conflict resolutions for three years or until
the resolution of any NSF action involving those records,
whichever is longer.

Certify that identified conflicts
of interest will be managed, reduced or eliminated
prior to the Institution's expenditure of any funds
under the award.

The following certification for
proposals is now part of NSF endorsement pages that will
be included with each proposal.

The Institution certifies that
we have implemented and are managing a written policy
on conflicts of interest consistent with the provisions
of Grant Policy Manual Section 510; that, to the best
of our knowledge, all financial disclosures required
by the conflict of interest policy were made; and that
actual or potential conflicts of interest, if any, were,
or prior to funding the award, will be satisfactorily
managed, reduced or eliminated prior to the expenditure
of funds on this award in accordance with the Institution's
conflict of interest policy, or disclosed to NSF.

The following certification by all
Co-Principal Investigators is required by signing the
Green Sheets of submitted proposals.

I certify that I have read and
understand the Institution's conflict of interest policy.
To the best of my knowledge, I have made all appropriate
financial disclosures and will comply with any conditions
required by the Institution to manage, reduce or eliminate
actual or potential conflicts of interest.

The NSF policies outline the following
responsibilities for individuals who are responsible
for the design, conduct, or reporting of research or
educational activities funded or proposed for funding
by NSF:

They must disclose
to WHOI significant financial interests that exceed
$10,000 income or 5% equity, including the aggregate
financial interests of spouse and children, in any
entity whose financial interest would be affected
by research funded by NSF. Note that a "significant
financial interest" for equity is defined as being
5% or more OR any equity position whose reasonable
fair market value is $10,000 or more.

Disclosures are
to be made prior to submission of the proposal to
NSF. Disclosures must also be updated during the period
of the award, either on an annual basis, or when new
or reportable significant financial interests are
obtained. Note that NSF will require institutions
and investigators involved in large ongoing projects
to provide the required certifications for all continuing
grant applications exceeding $1,000,000 at the time
of the first funding increment that occurs after October
1, 1995.